630 Sansome Street
San Francisco, CA 94111-2214
415-705-1098 Text (TTY)
|File Code: 2090
Date: May 1, 1998
Subject: IMPROVING CONSERVATION OPTIONS FOR NATIONAL FORESTS IN THE SIERRA NEVADA
To: Forest Supervisors: Modoc, Lassen, Plumas, Tahoe, Eldorado, Stanislaus, Sierra, Inyo, Sequoia National Forests and LTBMJ
We have discussed with you the approach to the Sierra Nevada Conservation Framework (SNCF). The need and urgency for taking action are identified in SNEP, other scientific sources, the CASPO RDEIS and the CASPO FAC Report. We are now moving forward, in collaboration with State agencies, other federal agencies and numerous other partners, on all four tasks we outlined for this effort. This approach conforms with the Forest Service Natural Resource Agenda, specifically the two themes of watershed health and sustainable forest management and the principles of partnerships, science based decision making, collaborative stewardship and accountability. It also conforms with recommendations made in the CASPO FAC Report. PSW scientists are working in partnership with us to develop a strong scientific basis for all work required to assemble this framework.
The approach has both short and long term components. The four tasks are outlined below indicating probable time frames. Because the approach is based on collaboration and active engagement by partners, communities, communities of interest and stakeholders, it is possible that both time frames and details of each of the tasks may change as we proceed.
Task 1--this letter. The purpose is to clarify existing guidelines and identify relevant new information that should be considered in planning your FY98 and FY99 programs of work such that we improve conservation options for key resources at issue. These include Old Forests and Old Forest associated species(including California Spotted Owl and meso-carnivores/furbearers); Roadless Areas; Riparian and Aquatic Ecosystems; and, Fire and Fuels management.
Task 2--a synthesis of the need for new direction from existing science, scientific reports, and an evaluation of how implementation of CASPO Interim Guidelines affects the above mentioned key resources at issue. PSW scientists will draft the synthesis and participate in the evaluation, which will be subject to interagency and peer review prior to its use in focusing Task 3. Completion of this task is scheduled for mid-summer.
Task 3--development and adoption of forest plan amendments, together with required NEPA process. The amendments will conform the forest plans with new scientific information and protect resource values. This task will take 12 to 18 months to complete and will conform with forest plan amendment procedures and all NEPA requirements. I expect this task to completed by July of 1999.
Task 4--development of a long-range conservation framework that describes broad goals for the health and management of ecosystems in the Sierra and protocols for watershed level planning and implementation of actions to achieve those goals in coordination across the Sierra Nevada range. It is envisioned to be an open, fully collaborative process utilizing the interagency model that has evolved under the California Biodiversity Council (CBC) to provide leadership oversight and coordination at the local, regional and rangewide scales. This task will begin immediately and run concurrently with tasks 2 and 3, and may take three to four years to complete. It would be available to inform Forest plan and other landowner entity plan revisions.
The remainder of this letter constitutes Task 1. An overriding tenet in the policy guidance and clarification contained herein is the timely and appropriate use of new information as provided in 36 CFR 219.12(d) and 40 CFR 1500.1(b). Also, FSH 1909.15, part 18.1 requires review of new information to determine if there is need to change a decision that has not yet been fully implemented. What follows is predicated on new information since 1993.
This letter does not apply to any project for which there is an awarded contract or, in the case of proposed timber sales, where bids have already been opened. Fuels, timber or road projects should comply with the direction stated below regardless of whether they have signed NEPA decisions. This letter applies to the 8 Sierra Nevada national forests and those parts of the Lassen and Modoc National Forests not under the direction of the Northwest Forest Plan. All laws, rules, and regulations applicable to the management of National Forest System lands continue to apply.
MANAGEMENT OF OLD FORESTS, FOREST CARNIVORES AND CALIFORNIA SPOTTED OWL
The Region recognizes that old forests are valuable natural resources worthy of protection, restoration and management. The management of old and late successional forests and species dependent on these ecosystems continues to be a matter of concern and controversy. A broad range of scientifically sound alternatives for old forest conservation and management have been proposed. There is continuing scientific dialogue on some of the details of how old forests should be defined in the Sierra Nevada, at what geographic scale the definitions apply, and how such forests should be managed to sustain their many values. Criteria for old forests contained in various scientific studies and reports differ.
The need for conserving California spotted owl habitat in order to enhance the owl's viability is widely recognized. The Decision Notice for the 1993 California Spotted Owl Sierran Province Interim Guidelines Environmental Assessment (CASPO) included an option to apply "adaptive management" when a project-specific biological evaluation clearly demonstrated that the intent of the CASPO recommendations was better achieved through an alternative prescription. The region recognizes the value of continued dialogue to address questions from some scientists and members of the public regarding habitat and it's management.
Concerns regarding the continued viability of mesocarnivores (animals historically known as furbearers) must also be addressed in the Sierra Nevada. In 1990 and 1994 petitions were made to the U.S. Fish and Wildlife Service to list the Pacific fisher under the Endangered Species Act, based on status review findings.
In FY99 the Region will initiate work with PSW scientists and other mesocarnivore experts to refine habitat models for marten (Martes americans) and fisher (Martes pennanti) and use these to map suitable habitats throughout the Sierra Nevada. In addition, a Population Viability Assessment will be initiated by PSW in FY99. Information from the viability assessment plus the above modeling and mapping will be used to develop management strategies to maintain viable, well-distributed populations of marten and fisher in the Sierra Nevada as part of Tasks 3 and 4.
What We Will Do in FY98 and 99:
Old Forest: The PSW Station, working with scientists from other Stations, agencies and universities as appropriate, will help analyze the existing methods of defining old forests and assess how this knowledge can be integrated into forest management. Until this information is available, I am suggesting you avoid proposing or offering timber sales within high-quality late seral/old forests as identified in the SNEP Report (Vol. II, Chapter 21, polygons ranked 4 or 5). We will continue our current practice of removing trees that are a demonstrated hazard to human safety, regardless of size. We will also continue to meet our wildfire suppression obligations. management activities intended to reduce fire hazard to old forests should be based on careful analysis of the present condition in the project area. The analysis, which should be included in the project NEPA documents, should include: 1)a description of the fuel profile, modeling of the fire behavior, and expected effects of typical fire behavior under current conditions and after treatment; 2) an evaluation of the likelihood of an ignition occurring, based on the ignition rate and large fire history; and, 3) the relative risk to old forests and associated species of deferring fuels reduction management.
California Spotted Owl: Forests will continue to apply the CASPO Interim Guidelines as part of current policy. A regional technical, interdisciplinary oversight team made up of RO and PSW staff will review all timber and fuels management projects proposed under the adaptive management provision of the Interim Guidelines and make a recommendation on whether they should proceed as planned.
The Regional Forester will review their results for consistency with policy. Projects that have been approved as scientific research or administrative studies will be exempted from this review. Projects proposed under the adaptive management provision should:
1) include specific provisions for directly monitoring the effects on Spotted owls and their habitat, and
2) reflect consideration of the recommendations for adaptive management projects outlined in the 2400/2670/1950 memo of 11 December 1996 on Adaptive Management Under CASPO Interim Guidelines. The Region will soon distribute further clarification on the regional technical oversight team, including a set of instructions on how to submit projects for review.
Mesocarnivores: The direction under "Old Forest" above will help maintain options for mesocarnivores during the period prior to completion of any new direction resulting from Tasks 2 and 3. For all projects with suitable mesocarnivore habitat, Forests should analyze direct, indirect, and cumulative effects, using the biological evaluation process to disclose those effects on legacy structure and large hardwood components. Additionally, the strategy outlined below to analyze the current habitat and management situation will form the basis of subsequent NEPA analysis.
Most Sierra Nevada National Forests have established management networks for marten and/or fisher. A PSW led science team will review the identification process and management of these networks for adequacy in maintaining habitat for viable well-distributed populations of marten and fisher.
1. To assist PSW scientists in their review of current R5 habitat management for marten and fisher, Forests with networks are requested to provide their GIS or hard copy maps to the Remote Sensing Lab for creation of a digitized Sierra-wide map of these networks no later than five weeks from date of this letter. Ralph Warbington will be the contact for the GIS work. Each responding Forest should then complete a questionnaire (which will be designed in early May by the RO, field and PSW) to elucidate the processes used and decisions made in identifying the network, and in determining management of the network.
2. To maintain habitat options for marten and fisher, the Forests with identified networks should: (A) defer management activities that significantly decrease the legacy structural elements of large diameter live trees, snags and down logs in forest carnivore habitat network areas not covered by CASPO standards (these are the elements that appear to be most critical to selection of habitats by marten and fisher, and are not replaceable within a timeframe conducive to uninterrupted use of the habitat) ; and (B) retain standing large diameter (>40cm or 15 inches dbh) hardwoods in the form of black oak and California live oak within the forest carnivore habitat networks. This approach should be coordinated with and be reflected in fuels treatment projects.
3. We will use the regional oversight process being established for review of Biological Evaluations (BE) concerning the effects of adaptive management under the CASPO Interim Guidelines to examine how potential effects to marten and fisher are being identified, analyzed and mitigated (refer to the "California Spotted Owl" section of this letter). The BEs (will be reviewed for adequacy of analysis regarding direct, indirect and cumulative effects of implementing adaptive management prescriptions on marten and fisher. This review will be facilitated by including forest carnivore subject matter specialists) on the oversight review team.
4. Any Sierra Nevada national forest that has not identified a marten/and or fisher habitat network should do so by early FY99. Until a network is identified, adaptive management projects will be submitted for review by the Regional Oversight Team.
Projects proposed without the adaptive management provision should either (A) survey suitable habitat, as determined using Freel 1991 and more recent information provided in Zielinski and Kucera 1995: "American marten, fisher, lynx and wolverine: survey methods for their detection", and use the protocol established in Zielinski and Kucera (1995); or (B) In areas of suitable habitat that are not surveyed, assume the species are present.
It is current Forest Service policy to proceed with road building projects in inventoried roadless areas only after full disclosure in an Environmental Impact Statement. The Chief will soon issue a new policy concerning management of roads and roadless areas. Until that time, we should avoid the extra effort required in an EIS process and propose no new roads in inventoried roadless areas.
RIPARIAN AND AQUATIC ECOSYSTEMS
We remain committed to the maintenance and restoration of the health of the riparian and aquatic systems under our stewardship. Since Forest Plans in the Sierra Nevada were first implemented, much new information has been developed that can assist us in our management. while any adjustment to current Forest Plan Standards and Guidelines must depend on the completion of a NEPA process, there are things we can do now to help us retain our conservation options for these systems.
What we will do
Any new projects in riparian areas should be specifically designed to protect, restore and/or enhance riparian and aquatic ecosystems.
When planning projects, you should consider new scientific information that addresses the full range of ecological attributes and geomorphic and hydrologic processes that are important to riparian and aquatic function. Summaries of this information can be found in SNEP, Volume 2 Ch. 36, and FEMAT Chapter V. Current Forest plan RMZ widths should be considered minimums for all projects.
The PSW Station will assist the Region in analyzing existing approaches used to define riparian areas and assess how this knowledge can be integrated into management strategies for riparian and aquatic ecosystems.
FIRE AND FUELS MANAGEMENT
The Cal Owl RDEIS, FAC Report and the SNEP Report identified large, high severity wildfires as a threat to natural resources in the Sierra Nevada. All of these reports also stressed the importance of fire as a major natural disturbance influence in shaping and maintaining Sierra Nevada forests in a healthy, resilient and productive condition and recommended increases in the use of prescribed fire and fuel treatments. Each report emphasized the need to restore fire to the ecosystem to reduce the impacts of severe wildfires to owl habitat, riparian areas, old forests and other ecosystem attributes. This letter is intended to reinforce this theme, encourage the national forests to continue their emphasis on fire and fuel management, protect ecosystems and improve conservation options, and encourage partnerships with other agencies to make our work more effective.
At the regional level, we intend to continue our full participation in the interagency California Fire Alliance which should support and encourage collaborative project planning and coordination at the forest level.
What we will do
All fuel treatment projects should be designed in a manner consistent with our intent to preserve conservation options as outlined under the previous elements above. The following criteria should be used to identify fuels management priorities in Sierra Nevada national forests. They are ranked in order of importance:
1) Treatments in high risk interface areas with special emphasis on projects in short interval, fire dependent ecosystems;
2) Treatments that are planned cooperatively with federal, state and local partners to develop common fuels, risk and hazard layers and that present opportunities for using existing fuels funds more effectively;
3) Treatments which reduce expected long range fire suppression costs by restoration and maintenance of fire adapted ecosystems at risk from damaging wildfire, beyond the interface areas; and
4) Treatments within and adjacent to wilderness areas that potentially reduce wildland fire possibilities.
This ranking should help determine where adjustments can and should be made to treat fuels while we improve our short-term conservation options for old forests, riparian and aquatic ecosystems and forest carnivores and the California spotted owl.
In the near-term, we may incur a somewhat greater risk of wildfire in some areas where we choose to defer fuels reduction projects in order to meet the other objectives stated in this letter. And thus the risk of losing habitat and old-forest values is a potential.
Tasks 3 and 4 will help us determine how to balance these short-term conservation needs with the reality that we need to manage and reduce fuels to maintain our long-term options.
Long-term options include making sure we retain the ability to manage fire in the future. National Forests must maintain a minimum number of resources in the Sierra Nevada to suppress unwanted wildland fires and to provide the expertise needed to accomplish fuels management and prescribed burning objectives. Forest have been assigned a minimum fire preparedness resource target in the final FY98 planning and budget advice, that defines a minimum level of suppression resources on each of the 10 National Forests in the Sierra Nevada. The Forests should maintain these resources.
In summary, this letter provides advice on preparing and implementing our FY98 and FY99 programs. Our intent is to improve our conservation options as we move toward future forest plan amendments and revisions. This letter references new information that must be considered. I expect consistency of application and full coordination as we proceed. If you have any questions on how to proceed, please let us hear from you in a timely fashion. Thanks for your continued efforts to move us forward with our Sierra strategy.
/s/ G. Lynn Sprague
G. LYNN SPRAGUE